SEC Comment Letter 0000000000-23-009857 to Xperi Inc. (XPER) (CIK 0001788999) (XPER)
Xperi Inc. (XPER) (CIK 0001788999)
Date: Sept. 6, 2023 · CIK: 0001788999 · Accession: 0000000000-23-009857
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File numbers found in text: 001-41486
Letter
United States securities and exchange commission logo September 6, 2023 Robert Andersen Chief Financial Officer Xperi Inc. 2190 Gold Street San Jose, CA 95002 Re:Xperi Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed March 6, 2023 File No. 001-41486 Dear Robert Andersen: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Consolidated Financial Statements Consolidated Statements of Operations, page F-2 1.Please tell us what consideration was given to separately presenting revenue and cost of revenues from products and from services. As part of your response, please provide us with such information for the periods presented. Refer to Rule 5-03(b)(1) and (2) of Regulation S-X. Note 4. Revenue, page F-15 2.Please tell us what consideration was given to providing revenue disaggregation by business model (technology licensing and technology solutions). In this regard we note that you provided such disclosures in your recent Form 10 and the September 30, 2022 Form 10-Q. Additionally, tell us what consideration was given to providing revenue disaggregation disclosures based on the pattern of recognition, such as over-time and point
FirstName LastNameRobert Andersen Comapany NameXperi Inc. September 6, 2023 Page 2 FirstName LastName Robert Andersen Xperi Inc. September 6, 2023 Page 2 in time, to depict the timing and uncertainty of revenues and cash flows. As part of your response, please provide us with such revenue disaggregation information for the periods presented. Refer to ASC 606-10-50-5 and ASC 606-10-55-89 through 55-91. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Joyce Sweeney, Senior Staff Accountant at 202-551-3449 or Christine Dietz, Senior Staff Accountant at 202-551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Becky Marquez
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United States securities and exchange commission logo
September 6, 2023
Robert Andersen
Chief Financial Officer
Xperi Inc.
2190 Gold Street
San Jose, CA 95002
Re:Xperi Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed March 6, 2023
File No. 001-41486
Dear Robert Andersen:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Consolidated Financial Statements
Consolidated Statements of Operations, page F-2
1.Please tell us what consideration was given to separately presenting revenue and cost of
revenues from products and from services. As part of your response, please provide us
with such information for the periods presented. Refer to Rule 5-03(b)(1) and (2) of
Regulation S-X.
Note 4. Revenue, page F-15
2.Please tell us what consideration was given to providing revenue disaggregation by
business model (technology licensing and technology solutions). In this regard we note
that you provided such disclosures in your recent Form 10 and the September 30, 2022
Form 10-Q. Additionally, tell us what consideration was given to providing revenue
disaggregation disclosures based on the pattern of recognition, such as over-time and point
FirstName LastNameRobert Andersen
Comapany NameXperi Inc.
September 6, 2023 Page 2
FirstName LastName
Robert Andersen
Xperi Inc.
September 6, 2023
Page 2
in time, to depict the timing and uncertainty of revenues and cash flows. As part of your
response, please provide us with such revenue disaggregation information for the periods
presented. Refer to ASC 606-10-50-5 and ASC 606-10-55-89 through 55-91.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Joyce Sweeney, Senior Staff Accountant at 202-551-3449 or Christine
Dietz, Senior Staff Accountant at 202-551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Becky Marquez